Massachusetts Institute of Technology
IN-1: Academy-Industry Connections

MIT has numerous policies governing industry sponsored research, conflicts of interest, access to data, and publishing rules that meet the credit requirements. See the data sources and notes at the bottom of this credit documentation for more information.

DISCLOSURE REQUIREMENTS
(Excerpt taken from MIT’s Policy and Procedures on Conflicts of Interest in Research: https://coi.mit.edu/policy/disclosure-requirements.)

Full and prompt disclosure of Significant Financial Interests (including, for PHS Investigators, Sponsored Travel) is critical to MIT’s ability to identify, manage, and eliminate Financial Conflicts of Interest. Investigators must describe a Related Entity’s business focus, their work or role with the Related Entity and any relationship to their Institutional Responsibilities. Please note: All MIT faculty and staff must also disclose certain information with respect to conflicts of interest in their annual report on Outside Professional Activities and Interests.

1. Creating a COI disclosure. An Investigator must create a COI disclosure in Coeus, which discloses the Investigator’s Significant Financial Interests and how they relate to the Investigator’s Institutional Responsibilities. Once approved, the disclosure becomes a master disclosure, which maintains an ongoing record of the Investigator’s proposals, awards, Significant Financial Interests, all approved disclosures and, for PHS Investigators, Sponsored Travel, for as long as the Investigator remains at MIT. See coi.mit.edu for more details.

When an Investigator joins a research project already in progress, an Investigator must disclose to MIT his or her Significant Financial Interests prior to the Investigator commencing participation in the research project.

2. Maintaining a master disclosure.
2.1. An Investigator must disclose to MIT any new Significant Financial Interests within a reasonable period (generally 90 days) following the date on which the Significant Financial Interest is acquired or arises. PHS funded Investigators must disclose any new Significant Financial Interest within 30 days following the date on which the Significant Financial Interest is acquired or arises and any Sponsored Travel within 30 days after completing the travel.
2.2. Disclosures must be updated at least every 12 months and Investigators will be notified of the expiration date via email.

REVIEW, EVALUATION, AND RESOLUTION
(Excerpt taken from MIT’s Policy and Procedures on Conflicts of Interest in Research: https://coi.mit.edu/policy/review-evaluation-and-resolution.)

The Designated Official will determine if the Significant Financial Interest identified in a COI disclosure is related to the Investigator’s Institutional Responsibilities. The Designated Official will be the Conflict of Interest Officer, the Department, Lab, or Center Head, or another member of the senior administration, depending on the circumstances.

The Conflict of Interest Officer will review all disclosures, and when possible, make the determination. In complex cases, the Department, Lab, or Center Head or member of the senior administration will make the determination If the Designated Official determines that the Significant Financial Interest is related to the Investigator’s Research, the disclosure will be submitted to the COI Committee for determination as to whether the Significant Financial Interest constitutes a Financial Conflict of Interest or the appearance of a Financial Conflict of Interest and, if so, whether it can be managed.

The COI Committee will submit a recommendation to the Institutional Official. The Institutional Official will then undertake his or her own evaluation and will determine whether the Investigator will be required to eliminate or manage the Financial Conflict of Interest, as appropriate. The Institutional Official may suspend all relevant activities until the Financial Conflict of Interest is resolved.

SIGNIFICANT FINANCIAL INTEREST
(Excerpt taken from MIT’s Policy and Procedures on Conflicts of Interest in Research: https://coi.mit.edu/policy/definitions#sfi.)

A financial interest is deemed to be significant if:

1. The aggregate value of Remuneration and Equity Interests in lieu of payment received from a US or foreign publicly traded entity during the 12 month period preceding the disclosure exceeds $5,000; or
2. The aggregate value of Equity Interests in a US or foreign publicly traded entity exceeds $5,000 and the entity is sponsoring any of the Investigator’s research; or
3. The aggregate value of Equity Interests in a US or foreign publicly traded entity exceeds $100,000 and the entity’s business, or any portion thereof, reasonably appears to be related to any of the Investigator’s Institutional Responsibilities; or
4. The aggregate value of Remuneration received from a US or foreign non-publicly traded entity or non-profit institution received during the 12 month period preceding the disclosure exceeds $5,000; or
5. Any Equity Interest is held in a US or foreign non-publicly traded entity; or
6. The aggregate value of Remuneration received from a foreign governmental organization during the 12 month period preceding the disclosure exceeds $5,000; or
7. The aggregate value of income related to intellectual property rights and interests paid by an entity other than MIT exceeds $5,000.

The following policy is recognized at MIT as generally prohibiting the MIT academic community from participating in ghostwriting.

USE OF INSTITUTE NAME
(Excerpt taken from Section 12.3 of MIT Policies: https://policies.mit.edu/policies-procedures/120-relations-public-use-mit-name-and-facilities-use/123-use-institute-name.)

The Institute's name must not be used in ways that suggest or imply the endorsement of other organizations, their products, or their services. The use of the Institute's name, logo, seal, and photographs in the advertising and other promotional material and activities of outside organizations is prohibited when such use is likely to be understood as an endorsement, even if such an endorsement is not the intention of the person or organization seeking to use MIT's name. All proposals, therefore, for the use of MIT's name or other identification in advertising, sales literature and videos, and commercial publicity must be submitted to the Technology Licensing Office.

Massachusetts Institute of Technology and MIT are registered trademarks of the Institute. MIT trademarks are licensed to others for use in connection with such products as T-shirts and hats; they are not generally licensed for use in connection with MIT intellectual property, software, patents, and copyrightable material. Any issues relative to the use of trademarks in connection with products should also be referred to the Technology Licensing Office.

All faculty and staff members should assume responsibility for preventing misuse of the Institute's name. Misuse may arise from consulting activities, in public reports made by individuals, or through failure to record and clarify MIT's restrictions governing the use of results obtained during research or investigations on behalf of commercial firms. For this reason all agreements involving the use of Institute facilities, including use for press conferences or public announcements, should be coordinated with the News Office and with the Technology Licensing Office.

It is equally important that faculty and staff members not allow their own names to be used in ways that state or imply Institute endorsement in connection with project or product promotions. It should also be understood clearly that opinions expressed by a faculty or staff member in preparing a report or paper under a consulting agreement or personal service contract are the opinions of the individual and not an official position of the Institute. Use of the Institute letterhead or address or other identification that might associate the conclusion of the report with the Institute should be avoided.

Where publicity or advertising arising from personal, non-Institute research or consultation is concerned, faculty and staff members are advised to consult the Technology Licensing Office.

Any financial accounts — such as bank, brokerage, or mutual fund accounts — that include Massachusetts Institute of Technology or MIT in the account name or that use the MIT Federal Tax Identification Number must be used solely for approved Institute-related purposes. Such accounts must be authorized and established by the Office of the Treasurer. Contact the Office of the Deputy Treasurer or, in the case of student activities, the Student Organizations, Leadership and Engagement Office. Unauthorized use of the MIT Federal Tax Identification Number could result in the imposition of penalties by the US Internal Revenue Service.

OPEN RESEARCH AND FREE INTERCHANGE OF INFORMATION
(Excerpt taken from Section 14.2 of MIT Policies: https://policies.mit.edu/policies-procedures/140-research-policies-and-public-and-private-support/142-open-research-and-free.)

The encouragement of research and inquiry into intellectual areas of great promise is one of the most basic obligations MIT has to its faculty, to its students, and to society at large. The profound merits of a policy of open research and free interchange of information among scholars is essential to MIT's institutional responsibility and to the interests of the nation as a whole. Openness requires that as a general policy MIT not undertake, on the campus, classified research or research whose results may not be published without prior permission—for example, without permission of governmental or industrial research sponsors. Openness also requires that, once they are at MIT, foreign faculty, students, and scholars not be singled out for restriction in their access to MIT's educational and research activities.

RESEARCH PUBLICATION APPROVALS OR PERMISSIONS
(Excerpt taken from MIT’s Research Administration Services’ Research Policy Guidelines: https://ras.mit.edu/sites/osp/files/policy/internal-file/rpg_publication_restrictions1_0.pdf.)

MIT will not undertake research on the campus requiring permission or approval of government or industrial research sponsors prior to publication. MIT will allow a brief review-and-comment period (not to exceed 30-days) to request the deletion of a sponsor’s inadvertently included proprietary information or to request the filing of patent applications(s). Any further delay requires the approval of the Office of Sponsored Programs.

MIT has numerous policies governing industry sponsored research, conflicts of interest, access to data, and publishing rules that meet the credit requirements. The attached Conflict of Interest Policy is one of several referenced below. These must be considered in their entirety:

https://coi.mit.edu/policy
https://osatt.mit.edu/
https://ras.mit.edu/
https://policies.mit.edu/policies-procedures